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CARA Act Request for Public Comment on New Buprenorphine Training Requirements

Kana Enomoto
Principal Deputy Administrator
Substance Abuse and Mental Health Services Administration
5600 Fishers Lane

Rockville, MD 20857

Re: CARA ACT Request for Public Comment on New Buprenorphine Training Requirements

Dear Principal Deputy Administrator Enomoto:

The American Psychiatric Nurses Association (APNA) appreciates the opportunity to comment on the Comprehensive Addiction Recovery Act (CARA) of 2016 nurse practitioner and physician assistant training requirements (81 FR 63780). APNA is an organization of more than 11,000 members, committed to the practice of psychiatric-mental health nursing, health and wellness promotion through identification of mental health and substance use issues, prevention of mental health problems and the care and treatment of persons with psychiatric and substance use disorders. APNA is the only professional organization inclusive of psychiatric-mental health nurses at both the registered nurse (RN) and advanced practice (APRN) levels. APNA offers the following recommendations:

  1. We recognize that CARA language is specific in identifying only nurse practitioners (NPs). However, it is essential that we further define the types of advanced practice nurses (APRNs) who can prescribe buprenorphine. In psychiatric-mental health nursing, both Nurse Practitioners (NPs) and Clinical Nurse Specialists (CNSs) are qualified APRNs and have recognized prescriptive authority. Currently CARA extends buprenorphine prescriptive privileges only to NPs. Meaningful expansion of access to buprenorphine can only be achieved with legislative changes that give all APRNs with prescriptive authority (NPs, CNSs, Clinical Nurse Midwives, and Nurse Anesthetists) this authorization to prescribe buprenorphine.
  2. There currently exists an 8-hour approved waiver course which many nurses have completed. We recommend that those APRNs who have taken the existing 8 hours of MAT training required by DATA 2000 have this training to count towards the 24 hours of training required by CARA.
  3. Include the following educational content in the 24 hours of nursing education, given the APRN role and scope of practice: Treatment approaches and principles that promote success and reduce the risk for ongoing or worsening addiction and how to socialize new or unfamiliar providers to treat addiction (I.e.: principles or approaches specific to the population to whom they provide care).

Once again, APNA applauds SAMHSA’s efforts to address opioid addiction, misuse, and needless deaths by reducing barriers to medication assisted treatment through the implementation of CARA.